#tax-planning
Стратегическо данъчно планиране за минимизиране на задълженията и максимизиране на спестяванията
Section 2032A lets executors value qualifying farm or closely held business real property at productive use rather than fair market value, with a 2026 reduction cap of $1,460,000 — worth up to $584,000 in federal estate tax at the 40% rate. The election is irrevocable, requires material participation, and triggers a 10-year recapture period.
Section 245A grants a 100% dividends-received deduction on qualifying foreign dividends to U.S. C corporations, but only when the 365-day holding period, hybrid dividend, extraordinary disposition, and PTEP ordering rules all hold. This guide explains how the participation exemption coordinates with GILTI and Subpart F, the traps that disqualify the deduction, and the bookkeeping that keeps it defensible on audit.
A practical guide to the federal tax election that lets buyers and sellers of S corporations and consolidated-group subsidiaries treat a stock purchase as an asset purchase for tax purposes — covering Form 8023, the seller gross-up, purchase price allocation under Section 1060, and the mistakes that commonly kill the election.
Section 367 overrides corporate non-recognition rules the moment U.S. property crosses into a foreign corporation, forcing immediate gain on outbound asset and IP transfers. This guide explains Sections 367(a), (b), (d), and (e), the GRA and Form 8838 deferral path, the 10% Form 926 penalty, the TCJA expansion to goodwill and workforce in place, and the 2024 final regulations on IP repatriation.
Section 451(c) lets accrual-method SaaS businesses defer advance payments — annual subscriptions, gift cards, prepaid services — by one tax year. Here is how the AFS deferral method interacts with ASC 606, how to elect it on Form 3115, and where the timing traps lurk.
A practical guide to Section 469 for real estate investors and side-business owners — the seven material participation tests, the $25,000 active-rental allowance, the real estate professional carve-out, the short-term rental angle, and the disposition rules that release suspended losses.
For tax year 2026, businesses with a three-year average of gross receipts at or below $32 million can elect Section 471(c) to skip UNICAP, treat inventory as non-incidental materials and supplies, and file Form 3115 — often producing a one-time Section 481(a) deduction in the year of change.
Beneficiaries of taxable estates can claim a Section 691(c) income tax deduction for federal estate tax already paid on inherited IRAs and other IRD assets. This guide covers eligibility, the with-and-without calculation, where to claim it on Schedule A, and the errors that cost families six figures.
A practical walkthrough of IRC Section 7701(b) for globally mobile founders — the 31-day floor, the weighted three-year 183-day formula, exempt-individual rules, the closer connection exception (Form 8840), and treaty tie-breakers (Form 8833) — with a worked example showing how 130 U.S. days in 2026 can trigger worldwide taxation.
A Section 83(b) election lets founders and early employees pay ordinary income tax today on the full value of restricted stock instead of at each vest. Filed within 30 days on IRS Form 15620, it can convert millions of phantom ordinary income into long-term capital gain and start the QSBS holding clock on day one.
For the self-employed, a Solo 401(k) often shelters more than double what a SEP-IRA does at the same income — a $90,000 earner can contribute $47,000 vs. $22,500 in 2026. This guide covers the limits, the Roth option, the pro-rata rule, and the December 31 deferral deadline.
The step transaction doctrine lets the IRS treat a sequence of formally separate steps as one taxable transaction. This guide explains the three tests courts apply — end result, mutual interdependence, and binding commitment — the landmark cases (Gregory v. Helvering, Court Holding, Kimbell-Diamond), the 2026 transactions most exposed (1031 drop-and-swaps, pre-sale entity conversions, gifts before the estate exemption sunset), and the documentation habits that keep multi-step plans defensible.
